Sanders and Apna Networks Ltd - 2017-017 (9 August 2017)
- Peter Radich (Chair)
- Te Raumawhitu Kupenga
- Paula Rose QSO
- Leigh Pearson
- Laurie Sanders
BroadcasterApna Networks Ltd
Channel/StationApna Networks Limited
[This summary does not form part of the decision.]
Kaho Naa… Pyaar Hai (Say… You’re in Love), a Bollywood romantic thriller film, was broadcast on free-to-air television channel APNA TV between 3pm and 6pm. The film featured action scenes containing violence. The Authority upheld a complaint that the film breached a number of broadcasting standards. The film was broadcast unclassified and with an incorrect programme description, which meant audiences were unable to make an informed viewing choice and were unable to regulate their own, and their children’s, viewing behaviour. The film’s inclusion of violent imagery such as beatings, shoot-outs, murder and dead bodies, and the visual depiction of these acts occurring onscreen, warranted an AO classification and later time of broadcast on free-to-air television. The film’s content would have been outside audience expectations of the programme, and child viewers, who were likely to be watching at the time of broadcast, were unable to be protected from material that had the potential to adversely affect them. The Authority did not uphold the complaint under the law and order standard.
Upheld: Programme Information, Children’s Interests, Good Taste and Decency, Violence; Not Upheld: Law and Order
Orders: Section 13(1)(a) broadcast statement; section 16(4) costs to the Crown $1,500
 Kaho Naa… Pyaar Hai (Say… You’re in Love), a Bollywood romantic thriller film, was broadcast on APNA TV between approximately 3pm and 6pm on Tuesday 10 January 2017. The film was unclassified, and was described as a ‘cookery programme’ in the programme guide. The film featured action scenes containing strong violence, including images of:
- shoot-outs and other weapon use
- bloody injuries and blood spurts
- death and dead bodies
- a child character viewing a dead body
- references to criminal activity such as drug use and corruption.
 Laurie Sanders complained that it was unacceptable to broadcast an unclassified film, particularly one which contained violence, at a time when children were likely to be watching television.
 The issues raised in Mr Sanders’ complaint are whether the broadcast breached the programme information, children’s interests, good taste and decency, violence and law and order standards of the Free-to-Air Television Code of Broadcasting Practice.
 The members of the Authority have viewed a recording of the broadcast complained about and have read the correspondence listed in the Appendix. As the broadcast was in Hindi, the Authority also viewed an identical version of the film with English subtitles.
Nature of the programme
 Kaho Naa… Pyaar Hai is a Bollywood film originally released in the year 2000, which contains elements of the romance, action and crime film genres.
 The storyline of the first part of the film followed the developing romantic relationship between two young people, Sonia and Rohit.
 Sonia’s father Saxena, and her uncle Malik, were secretly running a drug cartel with the help of two corrupt police officers. After Rohit inadvertently witnessed Malik and the two officers shooting the Police Commissioner, Malik and the officers pursued Rohit and attempted to murder him. He was chased off a bridge, and was presumed to have drowned in the river below. Sonia, and Rohit’s friends and family, believed the incident was an accident.
 Unknown to the others at the time, Amit (Rohit’s younger brother) witnessed Rohit’s murder and was traumatised, becoming mute.
 Sonia fell into a deep depression following Rohit’s death, and her father sent her to stay with family in New Zealand. There she met Raj, who was the doppelganger of the deceased Rohit. Raj fell in love with Sonia, and accompanied her when she returned to India.
 Back in India, Raj was mistaken for his look-alike, Rohit, and Malik and the two corrupt police officers recommenced their pursuit of him. Raj and Sonia realised that Rohit must have been murdered, and that Amit witnessed the incident, and developed a plan to catch the killers.
 The two police officers then kidnapped Sonia. Raj went to her aid, and succeeded in rescuing Sonia and killing the officers. Malik arrived, and Sonia and Raj realised his criminal background and that he was responsible for pursuing Rohit and Raj.
 Sonia’s father Saxena then arrived and shot Malik. Amit also arrived and saw Malik’s dead body. It was revealed that Saxena was also involved in criminal activity, and he confessed in front of Sonia and Raj before being arrested.
 Sonia then confessed that she was in love with Raj too, and the two became engaged.
Specific scene subject to complaint
 The specific scene identified in Mr Sanders’ complaint was when Raj rescued Sonia from her kidnappers, killing them in the process (see paragraph ). This scene formed the climatic point of the film’s narrative, and occurred at the end of the film.
 The scene was relatively long, and can be summarised as follows:
- Raj arrived at the empty warehouse where the two corrupt police officers were holding Sonia, who was blindfolded. The officers lost sight of Raj and fired a gunshot, whilst trying to control a struggling Sonia.
- Raj punched one of the officers’ associates, and he fell screaming from a high metal beam to the roof of a shipping container far below.
- The officers told Sonia to call for Raj, and one of them hit her across the face when she refused. She was then pulled by her hair and pushed against a shipping container.
- Raj grabbed another of the officers’ associates from behind, body-slammed him onto a mat on the ground below, and punched him in the face. Raj lassoed another associate, pulled him down to the ground, and punched him repeatedly against a wall. He then threw the associate through a window.
- The officers prepared to shoot Sonia to bring Raj out of hiding, and held a gun to her head. At this point blood was clearly visible dripping from her mouth, and she was in evident distress.
- Raj lept into the air and, swinging from a metal chain attached to the ceiling, kicked both officers in the head. Raj grabbed Sonia and took her to safety.
- An extended fight sequence then ensued between Raj and the officers, with the men repeatedly kicking and punching each other at high speed, and at times using weapons such as blocks of wood or pipes. Raj smashed one of the officers’ heads against a concrete pillar and threw the other over a metal pipe. Close up shots of the officers’ injured and bloody faces, as they cried out in pain and distress, were shown.
- As Raj continued to beat the officers, Sonia repeatedly told him ‘Kill them Raj, kill them’ in a frenzy. Raj proceeded to kick and punch the bloodied and battered officers in slow motion, and broke the kidnappers’ limbs. The sound of the bone breaking was heard, and one the officer’s faces was shown in agony.
- Sonia’s uncle, Malik, arrived at the scene pointing a gun at Raj and Sonia. He fired the gun, as Sonia pushed his arm to misdirect the bullet. Malik then explained why he wanted to kill them, and that he was responsible for murdering the Police Commissioner.
- As Malik was about to reveal the name of his fourth accomplice, he was shot by Sonia’s father Saxena. The rest of the family, including Rohit’s younger brother Amit, also arrived on the scene. Amit saw Malik’s dead and bloody body, and it was revealed that he was the same man he saw call an unknown accomplice to Rohit’s murder. Raj used Malik’s phone to call this unknown accomplice, and Saxena’s phone rang, revealing his involvement in the criminal activity.
 We note that there were several other action scenes earlier in the film that contained violent content, such as the murder of the Police Commissioner and the high-speed chase of Rohit, which ultimately resulted in his death; as well as a flashback sequence when Amit (Rohit’s younger brother) witnessed the events leading to Rohit’s murder.
 In keeping with the general style of many Bollywood films, the violent events in Kaho Naa… Pyaar Hai were presented in an exaggerated, dramatic and at times clichéd style.
Overview of findings and freedom of expression
 The right to freedom of expression, including the broadcaster’s right to impart ideas and information and the public’s right to receive that information, is the starting point in our consideration of complaints. The right we have to express ourselves in the way we choose, and to receive information, is a fundamental freedom, but it is not an absolute freedom. It is nevertheless an important right, and we may only interfere and uphold complaints where the limitation on the right is reasonable and justified in a free and democratic society.1
 The broadcasting standards impose some justified limitations on the right to freedom of expression that are designed to protect audiences from harm. Where the standards are not met, there is greater likelihood that harm may result.
 The requirement to classify programmes is a fundamental tenet of the broadcasting standards system. Classifications, along with advisories (warnings), scheduling and other programme information, is an important way in which broadcasters inform audiences about the likely content of their programmes. Audiences are then able to regulate their own, and their children’s, viewing behaviour by making informed viewing choices. When audiences are adequately informed about the nature of a programme, it follows that they are less likely to be surprised or offended by its content and therefore that the broadcast is less likely to breach standards. Additionally, special care needs to be taken during school holidays, when children are more likely to be watching television and for longer periods of time.
 Broadcasters must ensure that appropriate classifications are given to all broadcast content except news, current affairs, sports and live content. The latter categories are exempt from the classification regime. If a programme is classified as anything other than G (General), there are restrictions on what time it can be shown.2
 In this case, Kaho Naa… Pyaar Hai was not classified, was broadcast at 3pm on free-to-air television during the G timeband, and was mistakenly described as a ‘cookery programme’ in the programme guide. As a dramatic, fictional programme, the film was required to be appropriately classified and scheduled. The lack of both a classification and correct information being provided about the programme removed the audience’s ability to make an informed viewing choice, and increased the chance for the programme – and in particular the violent content – to surprise or disturb them. In our view, this failure to provide reliable programme information demonstrates, at best, a severe lack of knowledge and understanding of the standards. At worst, it demonstrates contempt for the broadcasting standards regime.
 The lack of classification is a clear breach of the programme information standard. It also has a flow-on effect on the application of other broadcasting standards. A programme’s classification is a relevant consideration under other standards raised in this complaint – namely children’s interests, good taste and decency, and violence. This is because the provision of appropriate information about a programme indicates the target audience, whether it is within audience expectations of that particular programme, and the type of content it is likely to contain. These are relevant contextual considerations for the other standards raised.
 In our view the failure to classify this broadcast resulted in clear breaches of Standards 1, 2, 3 and 4. We expand our reasoning for this finding under each standard below.
 In finding that the broadcast breached four standards, we have considered whether upholding the complaint on these grounds is a justified limitation on the broadcaster’s right to freedom of expression and the audience’s right to receive the artistic work in the manner broadcast. The broadcaster’s failure to meet the requirements of the standards, including the obligation to classify programmes, meant there was a real risk that harm would be caused to viewers, including children, by unexpectedly exposing them to potentially distressing or disturbing content. This in our view clearly outweighs any competing freedom of expression rights that the broadcaster may have to entertain its viewers with this artistic work. We are not suggesting that Kaho Naa… Pyaar Hai should not have been broadcast at all. Rather, the film was required to be broadcast with an appropriate classification and in an appropriate timeband. With that in mind, we proceed to assess each standard in turn.
Was the programme correctly classified and screened in an appropriate timeslot?
 As we discussed above, the purpose of the programme information standard (Standard 2) is to ensure that audiences are properly informed about the content of the programmes on offer. Broadcasters must correctly classify programmes, screen them in the relevant timeband and use appropriate audience advisories (warnings) where necessary.
The parties’ submissions
 Mr Sanders submitted:
- The film was not classified and should have been classified AO and broadcast after 8.30pm.
- Violent material needs to be properly classified and the programme scheduled at an appropriate adult viewing time.
- There is no freedom available to show violent content in a child’s viewing time just because it is a holiday period.
 APNA submitted:
- The film was classified PGR and this classification was meant to screen prior to the film. However, due to an unexplainable ‘technical glitch’ which was ‘beyond [the broadcaster’s] control’, no classification went to air.
- Viewers were informed in advance through promos that there would be changes to APNA’s normal programming, and films were going to be screened during the holiday season.
- All television stations depict some form of PGR material, however children are not restricted from viewing this.
- It cannot completely restrict programmes to ensure they are suitable for all audiences.
 As discussed above in paragraph , as a fictional, dramatic programme broadcast on free-to-air television, Kaho Naa… Pyaar Hai was required to be classified either G, PGR or AO. Regardless of the broadcaster’s intention to classify the film, it went to air unclassified. This was a clear breach of the free-to-air television programme information standard which required the programme to be classified, and that classification to be displayed on the content. We do not accept that a breach of standards can be forgiven by the broadcaster asserting that the omission of a classification was a ‘technical error’ or out of its control. The classification of programmes is a critical cornerstone of our broadcasting standards system. It is the sole responsibility of the broadcaster and well within the broadcaster’s control.
 While we have already found a clear breach of the standard, for completeness we have also considered whether the broadcaster’s proposed classification of PGR was appropriate for the film. The available classifications for free-to-air television are defined as follows:3
G – General
Programmes which exclude material likely to be unsuitable for children. Programmes may not necessarily be designed for child viewers but should not contain material likely to alarm or distress them.
PGR – Parental Guidance Recommended
Programmes containing material more suited for mature audiences but not necessarily unsuitable for child viewers when subject to the guidance of a parent or an adult.
AO – Adults Only
Programmes containing adult themes and directed primarily at mature audiences.
 The Code also provides that G programmes may be screened at any time. PGR programmes may be screened between 9am and 4pm, and after 7pm until 6am, and AO programmes may be screened between midday and 3pm on weekdays (except during school and public holidays), and after 8.30pm until 5am.4
 This film contained material which we consider was primarily directed at mature audiences, and which warranted an AO classification and later time of broadcast, after 8.30pm. We have described that content in detail, at paragraphs  to .
 We acknowledge that, Kaho Naa… Pyaar Hai was a lengthy film (at approximately 164 minutes in length), and not all scenes necessarily contained adult material. However, images of beatings, blood and other injuries, shoot-outs, murder and dead bodies are not material that is suitable for child viewers, even with adult supervision. For this reason, a PGR classification, even if displayed, would have been inadequate in our view.5
 Even if the film was classified PGR and the PGR classification displayed, the broadcast time of 3pm-6pm was inconsistent with the requirements of the programme information standard. PGR-classified programmes may only be broadcast on free-to-air television between 9am and 4pm, and 7pm and 6am. Therefore the broadcast would have resulted in a breach, even in these circumstances. If the film had been classified AO – which we have found was warranted – it should only have been broadcast after 8.30pm (given it was during the school holidays).
 For these reasons, and having regard to our comments in relation to freedom of expression at paragraph , we uphold the complaint under Standard 2.
Did the broadcaster adequately consider children’s interests?
 The children’s interests standard (Standard 3) states that broadcasters should ensure children can be protected from broadcasts which might adversely affect them.
The parties’ submissions
 Mr Sanders submitted:
- The film was broadcast at a time many children would have been likely to be watching television, particularly as it was school holidays.
- The film contained material which would have been offensive and distressing to child viewers, including violent content and themes (particularly violence against women), graphic depictions of people in pain and distress, and potentially offensive and aggressive language.
- ‘Children are quick to pick up on bad language and physical demonstrations of violence even if they are in a dramatic programme’, Mr Sanders said.
 APNA submitted:
- Children would be able to watch the film with parental guidance.
- While some violence was shown towards the end of the film for a short period of time, this would not have had a negative impact on audiences of a younger age.
- Parents should guide and protect children by instilling good values in them, and this does not merely depend on television programmes depicting these values.
 As we have said, Kaho Naa… Pyaar Hai contained adult themes, including violence. It was broadcast during a time when children would be likely to be watching television – a weekday afternoon during the summer school holidays. It was shown without a classification, advisory or other information which would enable audiences to regulate their own, or their children’s, viewing behaviour. We are satisfied that by failing to appropriately classify and schedule the film, the broadcaster did not enable parents and caregivers to protect children from a film which had the potential to adversely affect them.
 While there were innocuous sections in the film, it featured a significant amount of violence, which had the potential to disturb and alarm children. Child viewers may not have appreciated the stylised presentation of such violence or that the events were not real. The violence shown onscreen in the final scene was repeated and prolonged, compounding its impact. Children may also have been particularly distressed by the character of the young boy (Amit) witnessing the violent events, including death, which occurred in the film.
 Accordingly, we find the broadcast breached the children’s interests standard and we uphold this part of the complaint.
Did the broadcast threaten current norms of good taste and decency?
 The purpose of the good taste and decency standard (Standard 1) is to protect audience members from viewing broadcasts that are likely to cause widespread undue offence or distress, or undermine widely shared community standards. Broadcasters should take effective steps to inform audiences of the nature of the programme, and enable viewers to regulate their own and their children’s viewing behaviour.6
The parties’ submissions
 Mr Sanders submitted:
- APNA did not inform viewers of the nature of the programme, therefore audiences were unable to regulate their own, and their children’s, viewing behaviour.
- APNA misled his and other viewers’ expectations of the programme, as he was expecting a cookery show as advertised in the programme guide.
 APNA submitted that other television broadcasters also screen PGR films and these are acceptable to audiences.
 The good taste and decency standard is concerned with what the target and likely audience expects from a particular programme, and whether, in the context of the broadcast, it threatened current norms of good taste and decency. As a further consequence of the film being unclassified, we consider Kaho Naa… Pyaar Hai breached the good taste and decency standard.
 The programme was mislabelled ‘cookery’ and was unclassified. Accordingly, the audience was not properly informed of what to expect. The content of the film would have been well outside audience expectations, as they would have been expecting a cookery programme. As a result the film was likely to offend or disturb a significant section of the audience, taking into account the nature of the programme information provided.
 We accordingly uphold this aspect of the complaint.
Did the broadcaster exercise adequate care and discretion when dealing with the issue of violence?
 The violence standard (Standard 4) states that broadcasters should exercise care and discretion when dealing with the issue of violence. Violent content should be appropriate to the context of the programme, and classified carefully.
The parties’ submissions
 Mr Sanders submitted:
- APNA did not exercise care and judgement, as violent content was shown at 6pm during children’s viewing times. The film was advertised as a cookery show, but instead depicted ‘ongoing, significant, graphic violence’.
- In particular, the film portrayed violence against women, which is unacceptable.
 APNA submitted that only a small portion of the film contained minimal violence.
 By failing to classify Kaho Naa… Pyaar Hai and by failing to provide adequate information, it follows that the broadcaster failed to exercise adequate care and discretion in dealing with the violence in this film. The concerns we have expressed above about specific violent content apply equally here.
 We acknowledge that the film’s violent content was highly stylised, which may have somewhat mitigated its impact. Regardless, appropriately classifying violent material and screening it in a corresponding timeband, thereby indicating who it is suitable for, is an important way in which broadcasters meet their obligations under this standard. This did not occur.
 We therefore also uphold the complaint under Standard 4.
Did the broadcast encourage viewers to break the law, or otherwise promote, condone or glamorise criminal activity?
 The purpose of the law and order standard (Standard 5) is to prevent broadcasts that encourage audiences to break the law, or otherwise promote criminal or serious antisocial activity.7 The standard is concerned with broadcasts that actively undermine, or promote disrespect for, the law or legal processes.
The parties’ submissions
 Mr Sanders submitted:
- The film showed illegal behaviour, including violence against men and women, and serious crime (during children’s viewing times).
- The distinction between fact and fiction was irrelevant, as child viewers find it difficult to differentiate between what is real and what is not, and will imitate what is shown, he said.
 APNA did not make any submissions specifically in relation to the law and order standard.
 While Kaho Naa… Pyaar Hai was not classified or appropriately scheduled, it does not automatically follow that the film actively promoted criminal or antisocial behaviour. Depicting criminal or illegal activity is insufficient in itself to result in a breach of this standard.
 Context is crucial in assessing a programme’s likely practical effect under this standard. A distinction will usually be drawn between factual, and fictional or dramatic, depictions.8 The film contained dramatic depictions of criminal behaviour, which was justified by the film’s narrative context and its crime/action genre elements. In this context, we are satisfied that the film would not be interpreted as encouraging or condoning criminal behaviour, and that it did not undermine law and order.
 For these reasons, we do not uphold this aspect of the complaint.
For the above reasons the Authority upholds the complaint that the broadcast by APNA Networks Ltd of Kaho Naa… Pyaar Hai on 10 January 2017 breached Standards 1, 2, 3, and 4 of the Free-to-Air Television Code of Broadcasting Practice.
 Having upheld aspects of the complaint, the Authority may make orders under sections 13 and 16 of the Broadcasting Act 1989. We invited submissions on orders from the parties.
Submissions on orders
 Mr Sanders submitted:
- Some sort of deterrent should be ordered in case there are future breaches. Should breaches occur on a regular basis, any fine up to $5,000 may not be a sufficient deterrent.
- APNA should be ordered to pay costs to the Crown, as this shows that there is a cost for not being sufficiently diligent in understanding the rules of broadcasting.
- APNA should be ordered to broadcast a statement summarising the complaint, the decision and the reasons why it was upheld, as well as a clear statement that it will not permit this sort of programme to be shown in any timeslot before 8.30pm in the future.
 APNA submitted:
- It has improved its classification system and tightened procedures to ensure that such an incident does not occur again.
- The broadcast in question occurred during a holiday period in which most of the staff were on leave and APNA was operating on a skeleton staff.
- It apologised to the complainant and this apology should be accepted.
- Being a niche broadcaster, it would be disadvantaged if a fine was ordered.
Authority’s decision on orders
 When we consider whether to make any orders in relation to a complaint, we take into account the following factors:9
- the seriousness of the breach, and the number of upheld aspects of the complaint
- the degree of harm caused to any individual, or to the audience generally
- the objectives of the upheld standard(s)
- the attitude and actions of the broadcaster in relation to the complaint (eg, whether the broadcaster upheld the complaint and/or took mitigating steps; or whether the broadcaster disputed the standards breach and/or aggravated any harm caused)
- whether the decision will sufficiently remedy the breach and give guidance to broadcasters, or whether something more is needed to achieve a meaningful remedy or to send a signal to broadcasters
- past decisions and/or orders in similar cases.
Costs to the Crown
 As we have said in our determination, we consider this was a serious breach of broadcasting standards. Classifications are a cornerstone of the broadcasting standards system, and are a vital way in which audiences are informed about the nature of a programme. APNA’s failure to classify a film which contained violent content resulted in a breach of four standards and had the potential to cause distress and offence to viewers (especially children). We also find APNA’s response to this complaint, and its lack of understanding of its obligations under the Free-to-Air Television Code, concerning.
 That being said, we recognise that this is the first complaint which has been upheld against APNA TV, and this decision provides clear guidance on the importance of appropriately classifying programmes, which we expect APNA to follow in future.
 For these reasons, and taking into account previous awards, we find that an award of $1,500 in costs to the Crown is warranted to mark the breach of standards. We note, however, that we will take this decision into consideration in the event that APNA fails to improve its operations and further breaches are brought to our attention.
 We also consider it appropriate that APNA publicly acknowledges the breach of standards to its audience by way of a broadcast statement. The statement should:
- reflect that the broadcast of Kaho Naa… Pyaar Hai without a classification breached the good taste and decency, programme information, children’s interests and violence standards of the Free-to-Air Television Code
- contain a comprehensive summary of the Authority’s decision and the reasons why those standards were breached
- reflect the Authority’s decision on orders.
 Our standard practice is for the wording of the statement to be drafted by the broadcaster and approved by the Authority.
1. Pursuant to section 13(1)(a) of the Act, the Authority orders APNA Networks Ltd to broadcast a statement. The statement shall:
- be broadcast within one month of the date of this decision
- be broadcast at a time and on a date to be approved by the Authority
- contain a comprehensive summary of the upheld aspects of the Authority’s decision
- be approved by the Authority prior to being broadcast.
The Authority draws the broadcaster’s attention to the requirement in section 13(3)(b) of the Act for the broadcaster to give notice to the Authority of the manner in which the above order has been complied with.
2. Pursuant to section 16(4) of the Act, the Authority orders APNA Networks Ltd to pay to the Crown costs in the amount of $1,500 within one month of the date of this decision.
The order for costs will be enforceable in the Wellington District Court.
Signed for and on behalf of the Authority
9 August 2017
The correspondence listed below was received and considered by the Authority when it determined this complaint:
1 Laurie Sanders’ formal complaint – 12 January 2017 (received by APNA on 15 February 2017)
2 APNA’s response to the complaint – 16 February 2017 (received by complainant on 4 March 2017)
3 Mr Sanders’ initial referral to the Authority – 20 February 2017
4 Mr Sanders’ confirmation of referral to the Authority – 10 March 2017
5 APNA’s response to the Authority – 28 March 2017
6 Mr Sanders’ final comments – 10 April 2017
7 APNA’s final comments – 15 May 2017
8 Mr Sanders’ submissions on the provisional decision and orders – 16 June 2017
9 APNA’s submissions on the provisional decision and orders – 5 July 2017
1 See sections 5 and 14 of the New Zealand Bill of Rights Act 1990, and Commentary: Freedom of Expression, Broadcasting Standards in New Zealand Codebook, page 6
2 Standard 2 – Programme Information
3 Guideline 2a to Standard 2 – Programme Information
4 As above
5 We note that an AO classification is consistent with ratings that similar versions of Kaho Naa… Pyaar Hai have received from overseas classification bodies. For example, the British Board of Film Classification gave the video version of the film a ‘15’ rating, meaning ‘suitable only for 15 years and over’: http://www.bbfc.co.uk/releases/kaho-naa-pyaar-hai-video. For the purposes of the Broadcasting Standards in New Zealand Codebook, a child is a person under the age of 14.
6 Guideline 1b to Standard 1
7 See, for example, Keane and Television New Zealand Ltd, Decision No. 2010-082
8 Commentary: Standard 5 – Law and Order, Broadcasting Standards in New Zealand Codebook, page 15.
9 Guide to the BSA Complaints Process for Television and Radio Programmes, Broadcasting Standards in New Zealand Codebook, page 58